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The Pacific Marine and Supply Company

Letter from David Gardiner to Fred Gehrman


Fred Gehrman
Unitek Environmental Companies
930 Mapunapuna Street
Suite 200
Honolulu, Hawaii 96819

Dear Mr. Gehrman:

Thank you for Pacific Marine and Supply Company's proposal to EPA's Project XL. Although your proposal was extremely thorough, I am sorry to inform you of our decision not to pursue it as an XL project.

XL proposals are reviewed carefully by a team from across all EPA regions and headquarters offices, and by representatives of state and tribal environmental agencies. EPA indicated it would consider proposals using eight criteria outlined in the 23 May, 1995, Federal Register notice launching Project XL. One consideration is environmental results -- the eXcellence part of XL. Based upon our review of the information you submitted, your proposal would not deliver the superior environmental results which the XL program was designed to foster. Although I agree that the Terra-Vit technology holds promise for the treatment of hazardous waste, it has been determined that Project XL would not be the best vehicle for this demonstration project.

Project XL is just one of many regulatory reinvention initiatives at EPA. For regulatory reinvention to be a success, some innovative ideas need to be embraced within the agency's existing programs. Pacific Marine's demonstration project provides an excellent opportunity to look for currently available mechanisms that permit innovation. Region nine staff has spoken frequently with Beth Ginsberg of Bogle & Gates to discuss alternatives to Project XL for Pacific Marine to conduct this demonstration project. A Research, Development and Demonstration Permit has been mutually agreed on by Ms. Ginsberg and EPA to be the most appropriate mechanism for this project Ray Sarasino and Joanne Asami of Region 9 will continue to work closely with Pacific Marine to provide technical assistance and to expedite the administrative process for this permit.

I want to stress that EPA's decisions on whether to accept or decline XL proposals are, by definition, judgment calls. Project XL has produced tremendous interest, and so competition for participation in the program is significant. Good arguments were made on both sides of the issues raised in your proposal. I hope that you will appreciate EPA's efforts to fully, fairly, and thoroughly consider your proposal.

If you have any questions or need further assistance, please contact Ray Sarasino at (415) 744-2040. Once again, thank you for your interest in Project XL, and your continued support of environmental protection.

David Gardiner
Assistant Administrator

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